Search - consideration

Results 161 - 170 of 1921 for consideration
Ruling

2001 Ruling 2001-0091383 - internal reorganization

Upon incorporation, Subco issued 1 common share to DC in consideration of $XXXXXXXXXX. 16. ... No other consideration will be received by DC Shareholder in respect of the Share Exchange. ... As sole consideration for such transfer, Qco will issue XXXXXXXXXX Qco Preferred Shares to DC. ...
Ruling

2002 Ruling 2002-0178983 - REFINANCING

On incorporation, Canco # 10 issued XXXXXXXXXX common shares to Principal for aggregate consideration of $XXXXXXXXXX. ... The consideration was paid by Canco # 10 by the issuance of a note payable to Principal. ... Canco # 3 paid consideration of $XXXXXXXXXX (the "License Amendment Fee") to Canco # 2 as consideration for Canco# 2 agreeing to amend the License Agreement by issuance of a note. ...
Ruling

1999 Ruling 9910443 - SAFE-INCOME DETERMINATION TIME

In consideration for the transfer, XXXXXXXXXX will issue to XXXXXXXXXX redeemable, retractable preference shares with a fair market value equal to the fair market value of the XXXXXXXXXX Shares at the time of the transfer. ... In consideration for the transfer, Subco will issue to XXXXXXXXXX the Subco Shares with a fair market value equal to the fair market value of the XXXXXXXXXX Shares at the time of the transfer. ... Subco will add an amount to the stated capital of the Subco Shares issued as consideration for the transfer of the XXXXXXXXXX Shares not to exceed the aggregate paid-up capital of the XXXXXXXXXX Shares. ...
Ruling

2008 Ruling 2008-0268041R3 - Purchase of Target and Bump

The consideration for this transfer was paid in full by Bidco by the issuance to BuyerSubco III of XXXXXXXXXX shares of Bidco. ... On XXXXXXXXXX, BuyerSubco III transferred all the shares of the capital stock of Bidco to Holdco II for FMV consideration. ... New Bidco will transfer all of the common shares of the capital stock of Target to Newco I for FMV consideration. ...
Ruling

2007 Ruling 2007-0227371R3 - Butterfly

Parent will transfer to TechCo, all of the DC TechCo Reorganization Shares held by Parent in consideration for the issuance by TechCo to Parent of XXXXXXXXXX TechCo Common Shares. ... The liabilities assumed as consideration for a property transferred pursuant to subsection 85(1) will not exceed the agreed amount in respect of that property. ...
Ruling

2003 Ruling 2003-0015553 - XXXXXXXXXX - Butterfly

The aggregate fair market value of all such consideration to be paid by each Newco to DC will be equal to the aggregate fair market value of the property transferred by DC to the particular Newco. ... The addition, under the BCA, to the stated capital account maintained for the Class D Shares that will be issued by each of Newco 1, Newco 2, Newco 3 and Newco 4, as the case may be, as consideration for the property transferred to the particular Newco by DC as described above, will not exceed the amount by which the aggregate of the agreed amounts in the particular Newco's subsection 85(1) election exceeds the aggregate of the fair market value of any non-share consideration paid by such Newco as consideration for such eligible property. ... (d) Each of Newco 1, Newco 2, Newco 3 and Newco 4 will receive DC lands in Proposed Transactions in areas subject to consideration for urban planning and development. ...
Ruling

2006 Ruling 2006-0203981R3 - Butterfly reorganization

On incorporation, A Co subscribed for at least XXXXXXXXXX Common Share of TC1 for nominal consideration. Similarly, Real Co subscribed for at least XXXXXXXXXX Common Share of TC3 for nominal consideration. Each of B Co and C Co subscribed for at least XXXXXXXXXX Common Share of TC2 for nominal consideration. ...
Ruling

2006 Ruling 2006-0178571R3 - Purchase of Target and Bump

The respective GP-Co will subscribe for one general partner unit of its New Partnership in consideration for CA$XXXXXXXXXX, and OPCO 4 will subscribe for XXXXXXXXXX limited partner units in each New Partnership for a consideration for CA$XXXXXXXXXX. 36. ... LP 4Partner will subscribe for one general partner unit of LP 4 in consideration for CA$XXXXXXXXXX, and GP will subscribe for XXXXXXXXXX limited partner units of LP 4 in consideration for CA$XXXXXXXXXX. 37. ... LP 4Partner will subscribe for partnership units in GP for a nominal cash consideration. 39. ...
Ruling

2008 Ruling 2007-0237361R3 - Sequential Butterfly

Cousinco2 acquired the XXXXXXXXXX Class C shares of TCl on XXXXXXXXXX in consideration for $XXXXXXXXXX. ... Cousinco3 acquired its XXXXXXXXXX Class C shares of TCl on XXXXXXXXXX in consideration for $XXXXXXXXXX. ... DC will subscribe for 1 Realco Common Share in consideration for $XXXXXXXXXX. 44. ...
Ruling

2021 Ruling 2019-0827591R3 - Split-up butterfly

A subscribed for XXXXXXXXXX DC Class A Common Shares for cash consideration of $XXXXXXXXXX per share; (b) Mr. B subscribed for XXXXXXXXXX Class B Common Shares for cash consideration of $XXXXXXXXXX per share; (c) Mr. ... D subscribed for XXXXXXXXXX Class D Common Shares for cash consideration of $XXXXXXXXXX per share. 9. ...

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